Plaintiff’s Motion for Reconsideration of Summary Adjudication

Factual and Procedural Background

Plaintiff Benedict Lobo (“Lobo”) began working as a Software Engineer for defendant Intel Mobile Communications North America Inc. (“Intel”) in October 2014. (First Amended Complaint (“FAC”), ¶17.) Plaintiff Lobo’s manager, defendant Drupad Perumandala (“Perumandala”) made disparaging remarks to plaintiff Lobo regarding his age and subjected plaintiff Lobo to hostility due to his ancestry/national origin. (FAC, ¶¶18 – 19.) Plaintiff Lobo was denied opportunities and benefits of employment that were essential to his continued success at defendant Intel. (FAC, ¶20.) Plaintiff Lobo made several workplace complaints to defendants regarding Perumandala’s actions. (FAC, ¶21.) Defendants retaliated against plaintiff Lobo’s objections by placing him on a corrective action plan (“CAP”). (FAC, ¶22.) Plaintiff Lobo believes defendants’ proffered CAP was a pretext for unlawful discrimination and hara